- 15 -
manner, in sustaining respondent’s proposed collection action,
and accordingly did not abuse her discretion. See Lunsford v.
Commissioner, 117 T.C. 183, 185 (2001). We sustain respondent’s
proposed collection action.
VI. Petitioner’s Motion for Sanctions Against Respondent
During trial, petitioner orally moved to impose sanctions on
counsel for respondent. In support of his motion, petitioner
asserted vaguely that “it was my belief that all of his
[respondent’s counsel’s] communications were vexatious and, at
that time, tactically not in my favor.” He complained broadly
that respondent’s counsel burdened him with an “inundation of
paperwork.” Although the Court invited petitioner to address his
motion on brief, petitioner failed to file any brief.
Section 6673(a)(2) allows the Tax Court in its discretion to
sanction an attorney admitted to practice before the Court if the
attorney has “unreasonably or vexatiously multiplied the
proceedings”. See Harper v. Commissioner, 99 T.C. 533 (1992)
(imposing sanctions under section 6673(a)(2) on the taxpayer’s
counsel for repeated and egregious conduct during the discovery
process that caused significant delay); Dixon v. Commissioner,
T.C. Memo. 2000-116 (imposing sanctions on counsel for the IRS
for intentionally misleading the Court).
Petitioner’s motion for sanctions is without basis or merit.
The record does not suggest that respondent’s counsel has engaged
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 Next
Last modified: May 25, 2011